The Complaint, filed by Plaintiffs National TPS Alliance, on behalf of its members, and seven individual TPS holders, alleges that DHS’s decision to vacate the January 2025 extension of Venezuela’s TPS designation and, subsequently, to terminate Venezuela’s 2023 TPS designation, were motivated by racism in violation of the Constitution’s Equal Protection guarantee and were arbitrary and capricious and contrary to law, in violation of the Administrative Procedure Act.